Why Compliance with Tax Laws is Crucial
In Pakistan, tax laws are flexible but mandatory in certain areas. Failure to comply with statutory obligations can lead to punishable offences, including fines and imprisonment.
According to Section 191 of the Income Tax Ordinance, 2001 (updated for 2026), prosecution may arise for non-compliance in the following areas.
Offences Punishable Under Section 191
Any person who, without reasonable excuse, fails to comply with the following obligations may face punishment:
| Obligation | Description | Punishment |
| Return Notices | Failing to comply with notices under sections 114, 116, 117 | Fine or imprisonment ≤ 1 year, or both |
| Advance Tax | Failure to pay advance tax under Section 147 | Fine or imprisonment ≤ 1 year, or both |
| Tax Collection/Deduction | Not collecting/deducting tax and paying it to Commissioner | Fine or imprisonment ≤ 1 year, or both |
| Furnish Particulars | Not furnishing accurate particulars under Section 165 | Fine or imprisonment ≤ 1 year, or both |
| Notices Compliance | Failing to comply with notices under Sections 140 or 176 | Fine or imprisonment ≤ 1 year, or both |
| Assistance to FBR | Not providing facilities or assistance under Section 175 | Fine or imprisonment ≤ 1 year, or both |
| Bank Account Declaration | Not declaring business bank accounts in forms or returns | Fine or imprisonment ≤ 1 year, or both |
| Computerization | Failure to integrate business with FBR computerized system | Fine or imprisonment ≤ 1 year, or both |
| Tax Invoice | Not generating tax invoice verifiable by FBR system | Fine or imprisonment ≤ 1 year, or both |
⚡ Tip: Compliance is not optional — even small omissions can lead to prosecution under Section 191.
Additional Penalties for Non-Filing After Conviction
If a person convicted under Section 191(a) still fails to submit the return of income or wealth statement within the period set by the court:
• Fine up to Rs. 50,000
• Imprisonment up to 2 years
• Or both, depending on the court’s decision
✅ Reminder: Filing promptly after receiving a notice or court order can minimize further penalties.
Step-by-Step: Avoid Punishable Offences
| Step | Action |
| 1 | Respond promptly to all FBR notices (Sections 114, 116, 117, 140, 176). |
| 2 | Pay advance tax as required under Section 147. |
| 3 | Ensure proper tax collection/deduction if applicable. |
| 4 | Submit accurate particulars for yourself and others under Section 165. |
| 5 | Provide reasonable facilities and assistance to FBR officers. |
| 6 | Declare all business bank accounts in returns/forms. |
| 7 | Integrate your business with FBR computerized systems. |
| 8 | Generate verifiable tax invoices through FBR systems. |
FAQs – Punishable Offences for Non-Compliance
Q1: What is the maximum punishment for failing to comply with FBR notices?
• Fine or imprisonment up to 1 year, or both.
Q2: What happens if I don’t file a return after being convicted?
• Fine up to Rs. 50,000 or imprisonment up to 2 years, or both.
Q3: Are small businesses also liable?
• Yes, all businesses and individuals are liable for Section 191 offences.
Q4: How can I avoid prosecution?
• File returns on time, respond to all notices, pay advance tax, and comply with FBR rules.
Compliance Checklist
Use this checklist to ensure your business is compliant with FBR tax laws and avoid Section 191 offences:
• Filed all income tax returns on time
• Paid advance tax
• Submitted accurate particulars
• Integrated business with FBR systems
• Generated FBR-verifiable tax invoices
Disclaimer: This article is for informational purposes only. For official guidance, consult the Federal Board of Revenue (FBR) or a certified tax professional.